As the federal Conservatives have been only too happy to point out at every possible opportunity, Prime Minister Justin Trudeau’s post-Christmas getaway to a private island owned by longtime family friend the Aga Khan left him with more than just a tan.

It also earned him the dubious distinction of being the first – and, thus far, only – sitting prime minister to be investigated by the federal ethics watchdog for not one but two potential violations of the conflict-of-interest rules governing MPs and public office holders.

He can, however, comfort himself with the knowledge that, had a similar law been in place in 1873, Sir John A. Macdonald likely would have been found to have run afoul of it through his involvement in the Pacific railway scandal that ultimately (and temporarily, it turned out) ended his tenure as prime minister.

That, at least, is the verdict of Ethics Commissioner Mary Dawson, who was asked to weigh in on the case by two Ottawa-area students earlier this year.

“The Conflict of Interest Act, which applies to public office holders, including the Prime Minister and members of his cabinet, prohibits them from accepting any gift that might reasonably be seen to have been given to influence them in the exercise of a power, duty or function,” she notes in her reply.

“In the case that you mention, Sir Hugh Allan’s gift of money could reasonably be seen to have influenced the awarding of the contract to construct the railroad and would not be allowed.”

She declined, however, to answer a follow-up question on whether “a good outcome excuses any wrongdoing to attain it.”

“My personal view … does not come into question in the performance of my role as commissioner,” she said.

“The Act does not allow me to consider whether an outcome was good or not. My role is to ensure that public office holders are respecting their obligations under the Act.”

And while the students didn’t ask what, if any, penalties Sir John A. might have faced as a result of such a ruling, a quick check of the Act suggests that — unless the commissioner of the day felt the facts were sufficiently untoward to refer the matter to the police — the only sanction he would have faced would have been a report to the House formally finding him to be in breach.

Then again, since he ended up stepping down in order to dodge a non-confidence vote, perhaps he would have managed to avoid such a decision ending up in the parliamentary record.

Here’s the full response with the names of the students removed to protect their privacy: